INGAA and the DEGT Pipelines, the Intervenors in Support of Respondent (hereinafter "Intervenors"), adopt the Commission’s statement of the ROFR issue:

Whether the Commission reasonably concluded that no term-matching cap was necessary for the right of first refusal because existing regulatory controls prevent the exercise of pipeline market power, and a term cap would distort the market and preclude the efficient allocation of capacity to the shipper valuing it the most.